Arthur J. Gallagher Insurance Brokers Limited Slavery and Human Trafficking Statement for Financial Year 2017

Transcription

1 Arthur J. Gallagher Insurance Brokers Limited Slavery and Human Trafficking Statement for Financial Year 2017 Introduction This Slavery and Human Trafficking Statement is made on behalf of Arthur J. Gallagher Insurance Brokers Limited ("AJGIBL") pursuant to section 54 of the United Kingdom Modern Slavery Act 2015 (the "Act"), for the financial year ending 31 December It sets out the steps that AJGIBL has taken, and is continuing to take, to ensure that modern slavery and human trafficking is not taking place within any part of our business, or in any of our supply chains. Our Business Organisation, Structure and Supply Chains Arthur J. Gallagher & Co ("AJG&Co") and its subsidiaries (the "Group") provide insurance brokerage and consulting services, and third party claims settlement and administration services to both domestic and international entities. Its brokers, agents and administrators act as intermediaries between insurers and their customers. The majority of the Group's revenue is generated in the USA with remainder derived primarily from Australia, Bermuda, Canada, the Caribbean, Latin America, New Zealand and the United Kingdom. AJG&Co is headquartered in Illinois, USA and it is a separate legal entity distinct from its subsidiaries that operate in 33 countries. The regulated subsidiaries in the UK, which includes AJGIBL, ultimately are structured under one UK holding company, Arthur J. Gallagher Holdings (UK) Limited, which is a subsidiary of AJG&Co. AJGIBL provides insurance brokerage and risk management services to a wide variety of commercial, industrial, institutional and governmental organisations. This includes planning, designing, and administering a wide array of insurance and risk management programmes. Our risk management services include claims and information management, risk and control consulting to help our clients reduce their risk costs and manage their risks effectively. Our supply chains are limited as we do not produce, manufacture or retail goods. AJGIBL does employ external service providers contracted for the maintenance and support of our offices, including cleaning and technical support services for office infrastructure and IT, and for outsourcing certain functions ordinarily performed by AJGIBL. Our Policy and Approach Holding persons in slavery or servitude, requiring persons to perform forced or compulsory labour, and the human trafficking of persons for exploitation, are crimes and violations of fundamental human rights. AJGIBL has zero tolerance to any form of slavery and human trafficking, and is committed to enforcing effective systems and controls to ensure neither is taking place in any part of our business or in any of our supply chains. AJGIBL is also committed to adhering to the highest standards of moral, professional, and ethical behaviour, and acting with integrity and transparency in all our business relationships. AJGIBL 1

2 therefore expects all those connected to our supplier network, or involved in procurement for the company or in any other part of our business, to comply with the AJG Global Standards of Business, which is available to view by accessing We comply with all laws, regulations and rules relevant to our business, and take our corporate and social responsibilities very seriously. We expect the same high standards from those we conduct business with. An endorsement of the Group's behavioural approach is it being consistently recognised by the Ethisphere Institute as one of the world's leading ethical companies. We are pleased to be part of the Group and continue to conduct ourselves in a way that actively demonstrates our high standards of integrity, professionalism and the strength of our Group's culture and core values. In addition, in June 2018 the employing entity for the UK Group became an official Living Wage Foundation accredited employer. Our Policies and Standards of Business Conduct AJGIBL operates in accordance with a number of internal global and UK Group policies and procedures to ensure that we are conducting business in an ethical and transparent manner. We identify and mitigate risk across a range of areas, including slavery and human trafficking, through integrating these policies and procedures. All UK Group policies are reviewed regularly and our UK Group internal governance requires the policies to be overseen by senior management, sponsored at a UK Executive level and to take account of our Global Standards of Business Conduct (together the "Standards"). Collectively the Standards address both the work environment and the specific issues associated with slavery and human trafficking. They include Standards for our own business workforce covering: harassment and discrimination; diversity and equal employment opportunity; safe workplaces; wage and hour laws. We have also taken steps to address slavery and human trafficking through the following UK Group policies and processes: Our Modern Slavery Policy outlines the behaviours expected of all employees; Our suppliers and service providers where appropriate, are required to confirm that their business does not contradict our zero tolerance approach; We endeavour to procure rights to terminate the contract at any time should any instances of modern slavery come to light. In addition we actively require our supplier and service providers comply with all laws and regulations that apply to their business, which may, for instance, include paying their employees at least the national minimum wage or the prevailing minimum wage for international suppliers; Our recruitment procedure includes UK work eligibility checks for all employees to safeguard against human trafficking or individuals being forced to work against their will. Our Remuneration and Incentive Policy addresses wage requirements. Our Procurement Policy establishes due diligence requirements. Our Business terms and conditions include the right to terminate relationships. AJG Global Standards of Business Conduct explains our values and the manner in which we behave as an organisation. Our Anti-Money Laundering and Anti-Bribery Policies help address the business environment 95/99 2

3 to reduce its potential for crime. Our Whistleblowing Policy ensures all employees know how to raise concerns about how colleagues are being treated or regarding practices within our business or supply chain without fear of reprisal. Due Diligence Our Procurement function carries out due diligence on a risk-based approach prior to contracting with any new supplier to the AJGIBL business. The level of due diligence carried out depends on the type of supplier; for example where a supplier is providing 'personnel'-driven services such as cleaning, a deeper review is performed to ensure that our contracts contain obligations that the supplier will comply with the Act. Due diligence on our critical suppliers is carried out on an annual basis. All critical suppliers need to confirm that they comply with the spirit and principles of the Act and where applicable, AJGIBL will review the supplier's statement to ensure that it is up to date and that the supplier is refreshing their commitments. Risk Management Overall, the nature of our business is considered to face a low risk that modern slavery and human trafficking will take place. While we have a focus on conducting risk analysis and risk management for those business partners, suppliers and service providers where risk may be higher, we are nonetheless keenly aware that the possibility does exist throughout our supply chains. Effectiveness AJGIBL will use various central resources, including our HR, Procurement and internal audit teams to monitor the effectiveness of the steps we have taken through applying performance indicators, which include, reports of instances where modern slavery or human trafficking practices have been identified, including from employees, the public, or law enforcement agencies, and grievance mechanisms and statistics. Further Steps In conjunction with our Group approach, we will continue to review what further steps can be taken to ensure our obligations under the Act are met in full. Specific measures include: Working with our supply chain to uplift salaries to the living wage for all personnel who provide us with services. Our approach to this is phased and currently applies to contract renewals and tender requests; Continued review of our policies, procedures and terms of business for the procurement of goods and services; Developing anti-slavery training for all employees. This statement is AJGIBL's seco d such statern t and was approved by its Board of Directors. Signature of Director: 96/99 3

4 Director's Name / Position: "wu c 26 Zl"-3C _.20\Kt Date: 97199

5 Arthur J. Gallagher (UK) Limited Slavery and Human Trafficking Statement for Financial Year 2017 Introduction This Slavery and Human Trafficking Statement is made on behalf of Arthur J. Gallagher (UK) Limited ("AJGUK") pursuant to section 54 of the United Kingdom Modern Slavery Act 2015 (the "Act"), for the financial year ending 31 December It sets out the steps that AJGUK has taken, and is continuing to take, to ensure that modern slavery and human trafficking is not taking place within any part of our business, or in any of our supply chains. Our Business Organisation, Structure and Supply Chains Arthur J. Gallagher & Co ("AJG&Co") and its subsidiaries (the "Group") provide insurance brokerage and consulting services, and third party claims settlement and administration services to both domestic and international entities. Its brokers, agents and administrators act as intermediaries between insurers and their customers. The majority of the Group's revenue is generated in the USA with remainder derived primarily from Australia, Bermuda, Canada, the Caribbean, Latin America, New Zealand and the United Kingdom. AJG&Co is headquartered in Illinois, USA and it is a separate legal entity distinct from its subsidiaries that operate in 33 countries. The regulated subsidiaries in the UK, which includes AJGUK, ultimately are structured under one UK holding company, Arthur J. Gallagher Holdings (UK) Limited, which is a subsidiary of AJG&Co. AJGUK provides insurance brokerage and risk management services to a wide variety of commercial, industrial, institutional and governmental organisations, on a direct or wholesale basis. This includes planning, designing, and administering a wide array of insurance and risk management programmes. Our risk management services include claims and information management, risk and control consulting to help our clients reduce their risk costs and manage their risks effectively. Our supply chains are limited as we do not produce, manufacture or retail goods. AJGUK does employ external service providers contracted for the maintenance and support of our offices, including cleaning and technical support services for office infrastructure and IT, and for outsourcing certain functions ordinarily performed by AJGUK. Our Policy and Approach Holding persons in slavery or servitude, requiring persons to perform forced or compulsory labour, and the human trafficking of persons for exploitation, are crimes and violations of fundamental human rights. AJGUK has zero tolerance to any form of slavery and human trafficking, and is committed to enforcing effective systems and controls to ensure neither is taking place in any part of our business or in any of our supply chains. AJGUK is also committed to adhering to the highest standards of moral, professional, and ethical 1

6 behaviour, and acting with integrity and transparency in all our business relationships. AJGUK therefore expects all those connected to our supplier network, or involved in procurement for the company or in any other part of our business, to comply with the AJG Global Standards of Business, which is available to view by accessing We comply with all laws, regulations and rules relevant to our business, and take our corporate and social responsibilities very seriously. We expect the same high standards from those we conduct business with. An endorsement of the Group's behavioural approach is it being consistently recognised by the Ethisphere Institute as one of the world's leading ethical companies. We are pleased to be part of the Group and continue to conduct ourselves in a way that actively demonstrates our high standards of integrity, professionalism and the strength of our Group's culture and core values. In addition, in June 2018 the employing entity for the UK Group became an official Living Wage Foundation accredited employer. Our Policies and Standards of Business Conduct AJGUK operates in accordance with a number of internal global and UK Group policies and procedures to ensure that we are conducting business in an ethical and transparent manner. We identify and mitigate risk across a range of areas, including slavery and human trafficking, through integrating these policies and procedures. All UK Group policies are reviewed regularly and our UK Group internal governance requires the policies to be overseen by senior management, sponsored at a UK Executive level and to take account of our Global Standards of Business Conduct (together the "Standards'). Collectively the Standards address both the work environment and the specific issues associated with slavery and human trafficking. They include Standards for our own business workforce covering: harassment and discrimination; diversity and equal employment opportunity; safe workplaces; and wage and hour laws. We have also taken steps to address slavery and human trafficking through the following UK Group policies and processes: Our Modern Slavery Policy outlines the behaviours expected of all employees; Our suppliers and service providers where appropriate, are required to confirm that their business does not contradict our zero tolerance approach; We endeavour to procure rights to terminate the contract at any time should any instances of modern slavery come to light. In addition we actively require our supplier and service providers comply with all laws and regulations that apply to their business, which may, for instance, include paying their employees at least the national minimum wage or the prevailing minimum wage for international suppliers; Our recruitment procedure includes UK work eligibility checks for all employees to safeguard against human trafficking or individuals being forced to work against their will. Our Remuneration and Incentive Policy addresses wage requirements. Our Procurement Policy establishes due diligence requirements. Our Business terms and conditions include the right to terminate relationships. AJG Global Standards of Business Conduct explains our values and the manner in which we behave as an organisation. 95/99 2

7 Our Anti-Money Laundering and Anti-Bribery Policies help address the business environment to reduce its potential for crime. Our Whistleblowing Policy ensures all employees know how to raise concerns about how colleagues are being treated or regarding practices within our business or supply chain without fear of reprisal. Due Diligence Our Procurement function carries out due diligence on a risk-based approach prior to contracting with any new supplier to the AJGUK business. The level of due diligence carried out depends on the type of supplier; for example where a supplier is providing 'personnel'-driven services such as cleaning, a deeper review is performed to ensure that our contracts contain obligations that the supplier will comply with the Act. Due diligence on our critical suppliers is carried out on an annual basis. All critical suppliers need to confirm that they comply with the spirit and principles of the Act and where applicable, AJGUK will review the supplier's statement to ensure that it is up to date and that the supplier is refreshing their commitments. Risk Management Overall, the nature of our business is considered to face a low risk that modern slavery and human trafficking will take place. While we have a focus on conducting risk analysis and risk management for those business partners, suppliers and service providers where risk may be higher, we are nonetheless keenly aware that the possibility does exist throughout our supply chains. Effectiveness AJGUK will use various central resources, including our HR, Procurement and internal audit teams to monitor the effectiveness of the steps we have taken through applying performance indicators, which include, reports of instances where modern slavery or human trafficking practices have been identified, including from employees, the public, or law enforcement agencies, and grievance mechanisms and statistics. Further Steps In conjunction with our Group approach, we will continue to review what further steps can be taken to ensure our obligations under the Act are met in full. Specific measures include: Working with our supply chain to uplift salaries to the living wage for all personnel who provide us with services. Our approach to this is phased and currently applies to contract renewals and tender requests; Continued review of our policies, procedures and terms of business for the procurement of goods and services; Developing anti-slavery training for all employees. This statement is AJGUK's second sy> y Wtement and was approved by its Board of Directors. Signature of Director: 96/99 3

8 Director's Name/ Position: ~ Ve ~ -, Date: 26 u \j E 2,Ol~6 97/99

9 Arthur J. Gallagher Services (UK) Limited Slavery and Human Trafficking Statement for Financial Year 2017 Introduction This Slavery and Human Trafficking Statement is made on behalf of Arthur J. Gallagher Services (UK) Limited ("AJG Services") pursuant to section 54 of the United Kingdom Modern Slavery Act 2015 (the "Act"), for the financial year ending 31 December It sets out the steps that AJG Services has taken, and is continuing to take, to ensure that modern slavery and human trafficking is not taking place within any part of our business, or in any of our supply chains. Our Business Organisation, Structure and Supply Chains Arthur J. Gallagher & Co ("AJG&Co") and its subsidiaries (the "Group") provide insurance brokerage and consulting services, and third party claims settlement and administration services to both domestic and international entities. Its brokers, agents and administrators act as intermediaries between insurers and their customers. The majority of the Group's revenue is generated in the USA with remainder derived primarily from Australia, Bermuda, Canada, the Caribbean, Latin America, New Zealand and the United Kingdom. AJG&Co is headquartered in Illinois, USA and it is a separate legal entity distinct from its subsidiaries that operate in 33 countries. The subsidiaries in the UK, which includes AJG Services, ultimately are structured under one UK holding company, Arthur J. Gallagher Holdings (UK) Limited, which is a subsidiary of AJG&Co. AJG Services does not publically trade and its primary business is to provide staff to the regulated subsidiaries in the UK. Our supply chains are limited as we do not produce, manufacture or retail goods. AJG Services does employ external service providers contracted for the maintenance and support of our offices, including cleaning and technical support services for office infrastructure and IT, and for outsourcing certain functions ordinarily performed by AJG Services. Our Policy and Approach Holding persons in slavery or servitude, requiring persons to perform forced or compulsory labour, and the human trafficking of persons for exploitation, are crimes and violations of fundamental human rights. AJG Services has zero tolerance to any form of slavery and human trafficking, and is committed to enforcing effective systems and controls to ensure neither is taking place in any part of our business or in any of our supply chains. AJG Services is also committed to adhering to the highest standards of moral, professional, and ethical behaviour, and acting with integrity and transparency in all our business relationships. AJG Services therefore expects all those connected to our supplier network, or involved in procurement for the company or in any other part of our business, to comply with the AJG Global Standards of Business, which is available to view by accessing 1

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11 We comply with all laws, regulations and rules relevant to our business, and take our corporate and social responsibilities very seriously. We expect the same high standards from those we conduct business with. An endorsement of the Group's behavioural approach is it being consistently recognised by the Ethisphere Institute as one of the world's leading ethical companies. We are pleased to be part of the Group and continue to conduct ourselves in a way that actively demonstrates our high standards of integrity, professionalism and the strength of our Group's culture and core values. In addition, in June 2018 AJG Services became an official Living Wage Foundation accredited employer. Our Policies and Standards of Business Conduct AJG Services operates in accordance with a number of internal global and UK Group policies and procedures to ensure that we are conducting business in an ethical and transparent manner. We identify and mitigate risk across a range of areas, including slavery and human trafficking, through integrating these policies and procedures. All UK Group policies are reviewed regularly and our UK group internal governance requires the policies to be overseen by senior management, sponsored at an UK Executive level and to take account of our Global Standards of Business Conduct (together the "Standards"). Collectively the Standards address both the work environment and the specific issues associated with slavery and human trafficking. They include Standards for our own business workforce covering: harassment and discrimination; diversity and equal employment opportunity; safe workplaces; wage and hour laws. We have also taken steps to address slavery and human trafficking through the following UK Group policies and processes: Our Modern Slavery Policy outlines the behaviours expected of all employees; Our suppliers and service providers where appropriate, are required to confirm that their business does not contradict our zero tolerance approach; We endeavour to procure rights to terminate the contract at any time should any instances of modern slavery come to light. In addition we actively require our supplier and service providers comply with all laws and regulations that apply to their business, which may, for instance, include paying their employees at least the national minimum wage or the prevailing minimum wage for international suppliers; Our recruitment procedure includes UK work eligibility checks for all employees to safeguard against human trafficking or individuals being forced to work against their will. Our Remuneration and Incentive Policy addresses wage requirements. Our Procurement Policy establishes due diligence requirements. Our Business Terms and Conditions include the right to terminate relationships. AJG Global Standards of Business Conduct explains our values and the manner in which we behave as an organisation. Our Anti-Money Laundering and Anti-Bribery Policies help address the business environment to reduce its potential for crime. Our Whistleblowing Policy ensures all employees know how to raise concerns about how colleagues are being treated or regarding practices within our business or supply chain without 2

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13 fear of reprisal. Due Diligence Our Procurement function carries out due diligence on a risk-based approach prior to contracting with any new supplier to the AJG Services business. The level of due diligence carried out depends on the type of supplier; for example where a supplier is providing `personnel'-driven services such as cleaning, a deeper review is performed to ensure that our contracts contain obligations that the supplier will comply with the Act. Due diligence on our critical suppliers is carried out on an annual basis. All critical suppliers need to confirm that they comply with the spirit and principles of the Act and where applicable, AJG Services will review the supplier's statement to ensure that it is up to date and that the supplier is refreshing their commitments. Risk Management Overall, the nature of our business is considered to face a low risk that modern slavery and human, trafficking will take place. While we have a focus on conducting risk analysis and risk management for those business partners, suppliers and service providers where risk may be higher, we are nonetheless keenly aware that the possibility does exist throughout our supply chains. Effectiveness AJG Services will use various central resources, including our HR, Procurement and internal audit teams to monitor the effectiveness of the steps we have taken through applying performance indicators, which include, reports of instances where modern slavery or human trafficking practices have been identified, including from employees, the public, or law enforcement agencies, and grievance mechanisms and statistics. Further Steps In conjunction with our Group approach, we will continue to review what further steps can be taken to ensure our obligations under the Act are met in full. Specific measures include: Working with our supply chain to uplift salaries to the living wage for all personnel who provide us with services. Our approach to this is phased and currently applies to contract renewals and tender requests; Continued review of our policies, procedures and terms of business for the procurement of goods and services; Developing anti-slavery training for all employees. This statement is AJG Services' second such statement and was approved by its Board of Directors. Signature of Director: 5 ' ~ a --, ~ 3

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15 Director's Name / Position: &WAC -)-H 186WN.~WSC TOXC Date:... 9M.ATON(f o2o g 4

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17 Pen Underwriting Limited Slavery and Human Trafficking Statement for Financial Year 2017 Introduction This Slavery and Human Trafficking Statement is made on behalf of Pen Underwriting Limited ("Pen") pursuant to section 54 of the United Kingdom Modern Slavery Act 2015 (the "Act"), for the financial year ending 31 December It sets out the steps that Pen has taken, and is continuing to take, to ensure that modern slavery and human trafficking is not taking place within any part of our business, or in any of our supply chains. Our Business Organisation, Structure and Supply Chains Pen is a wholly-owned subsidiary of Arthur J. Gallagher Holdings (UK) Limited and part of Arthur J. Gallagher & Co ("AJG&Co") group companies (the "Group"). AJG&Co is headquartered in Illinois, USA and it is a separate legal entity distinct from its subsidiaries that operate in 33 countries. The regulated subsidiaries in the UK, which includes Pen, are ultimately structured under one UK holding company, Arthur J. Gallagher Holdings (UK) Limited, which is a subsidiary of AJG&Co. The majority of the Group's revenue is generated in the USA with remainder derived primarily from Australia, Bermuda, Canada, the Caribbean, Latin America, New Zealand and the United Kingdom. Headquartered in London, Pen is a multi-class, multi-territory managing general agent ("MGA"). Performing many of the same functions as an insurer, Pen's services include underwriting, product development, claims, pricing, risk and control consulting. Our supply chains are limited as we do not produce, manufacture or retail goods. Pen does employ external service providers contracted for the maintenance and support of our offices, including cleaning and technical support services for office infrastructure and IT, and for outsourcing certain functions ordinarily performed by Pen. Our Policy and Approach Holding persons in slavery or servitude, requiring persons to perform forced or compulsory labour, and the human trafficking of persons for exploitation, are crimes and violations of fundamental human rights. Pen has zero tolerance to any form of slavery and human trafficking, and is committed to enforcing effective systems and controls to ensure neither is taking place in any part of our business or in any of our supply chains. Pen is also committed to adhering to the highest standards of moral, professional, and ethical behaviour, and acting with integrity and transparency in all our business relationships. As part of the Group, Pen therefore expects all those connected to our supplier network, or involved in procurement for the company or in any other part of our business, to comply with the AJG Global Standards of Business, which is available to view by accessing We comply with all laws, regulations and rules relevant to our business, and take our corporate 1

18 and social responsibilities very seriously. We expect the same high standards from those we conduct business with. An endorsement of the Group's behavioural approach is it being consistently recognised by the Ethisphere Institute as one of the world's leading ethical companies. We are pleased to be part of the Group and continue to conduct ourselves in a way that actively demonstrates our high standards of integrity, professionalism and the strength of our Group's culture and core values. In addition, in June 2015 the employing entity for the UK Group became an official Living Wage Foundation accredited employer. Our Policies and Standards of Business Conduct Pen operates in accordance with a number of internal global and UK Group policies and procedures to ensure that we are conducting business in an ethical and transparent manner. We identify and mitigate risk across a range of areas, including slavery and human trafficking, through integrating these policies and procedures. All UK Group policies are reviewed regularly and our UK Group internal governance requires the policies to be overseen by senior management, sponsored at an UK Executive level and to take account of our Global Standards of Business Conduct (together the "Standards"). Collectively the Standards address both the work environment and the specific issues associated with slavery and human trafficking. They include Standards for our own business workforce covering: harassment and discrimination; diversity and equal employment opportunity; safe workplaces; and wage and hour laws. We have also taken steps to address slavery and human trafficking through the following UK Group policies and processes: Our Modern Slavery Policy outlines the behaviours expected of all employees; Our suppliers and service providers, where appropriate, are required to confirm that their business does not contradict our zero tolerance approach; We endeavour to procure rights to terminate the contract at any time should any instances of modern slavery come to light. In addition we actively require our supplier and service providers comply with all laws and regulations that apply to their business, which may, for instance, include paying their employees at least the national minimum wage or the prevailing minimum wage for international suppliers. Our recruitment procedure includes UK work eligibility checks for all employees to safeguard against human trafficking or individuals being forced to work against their will. Our Remuneration and Incentive Policy addresses wage requirements. Our Procurement Policy establishes due diligence requirements. Our Business terms and conditions include the right to terminate relationships. AJG Global Standards of Business Conduct explains our values and the manner in which we behave as an organisation. Our Anti-Money Laundering and Anti-Bribery Policies help address the business environment to reduce its potential for crime. Our Whistleblowing Policy ensures all employees know how to raise concerns about how colleagues are being treated or regarding practices within our business or supply chain without fear of reprisal. 2

19 Due Diligence Our Procurement function carries out due diligence on a risk-based approach prior to contracting with any new supplier to the Pen business. The level of due diligence carried out depends on the type of supplier; for example where a supplier is providing 'personnel'-driven services such as cleaning, a deeper review is performed to ensure that our contracts contain obligations that the supplier will comply with the Act. Due diligence on our critical suppliers is carried out on an annual basis. All critical suppliers need to confirm that they comply with the spirit and principles of the Act and where applicable, Pen will review the supplier's statement to ensure that it is up to date and that the supplier is refreshing their commitments. Risk Management Overall, the nature of our business is considered to face a low risk that modern slavery and human trafficking will take place. While we have a focus on conducting risk analysis and risk management for those business partners, suppliers and service providers where risk may be higher, we are nonetheless keenly aware that the possibility does exist throughout our supply chains. Effectiveness Pen will use various central resources, including our FIR, Procurement and internal audit teams to monitor the effectiveness of the steps we have taken through applying performance indicators, which include, reports of instances where modern slavery or human trafficking practices have been identified, including from employees, the public, or law enforcement agencies, and grievance mechanisms and statistics. Further Steps In conjunction with our Group approach, we will continue to review what further steps can be taken to ensure our obligations under the Act are met in full. Specific measures include: Working with our supply chain to uplift salaries to the living wage for all personnel who provide us with services. Our approach to this is phased and currently applies to contract renewals and tender requests; Continued review of our policies, procedures and terms of business for the procurement of goods and services; Developing anti-slavery training for all employees. This statement is Pen's first s nd was approved by its Board of Directors. Signature of Director: Director's Name / Position: Date: Y-`l31^ 'C 20k,% 3

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